Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1958 and 1959 in the amounts of $148.50 and $677.95, respectively.
The issue for decision is whether amounts designated "per diem," paid to one of petitioners by his employer during the years 1958 and 1959, are includable in petitioners' gross income, and if so whether all or any portion of these amounts is deductible...
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